What Happens Now That the IRS is Awake Again?
In November 2025, the IRS officially resumed full collection operations after weeks of very limited staffing.
For taxpayers, that means letters arriving out of the blue, Revenue Officers resurfacing like long-lost relatives, and collection timelines snapping back into place like nothing happened.
For professionals like you—CPAs, attorneys, financial advisors, mortgage lenders, realtors—your clients rely on you to help them navigate the confusion that hits when the IRS flips the lights back on.
Many of your clients are already getting notices. More are coming.
Let’s talk about what actually matters.
Why This Matters
The shutdown didn't pause tax law. It didn't pause interest and penalties. And it didn't pause the IRS’s obligation to protect government revenue.
That’s why the IRS kept issuing Statutory Notices of Deficiency.
That’s why some Revenue Officers stayed active while others were furloughed.
That’s why levies, liens, passport certifications, and payment plan deadlines continued to move forward.
And that’s why your clients will turn to you first not that collections restarted and they don’t know what the next move should be.
This article breaks down what professionals need to know right now.
Today, We’re Covering 5 Key Points
Statutory Notices of Deficiency didn’t stop.
Penalties kept accruing—shutdown or no shutdown.
Revenue Officers are reactivating cases in batches.
Levies, liens, and passport holds are picking up again.
Lien discharges, lien subordinations, and lien withdrawals are back in motion.
1. Statutory Notices of Deficiency Still Carry a 90-Day Deadline
Shutdown or not, the IRS must legally issue a Statutory Notice of Deficiency before assessing additional tax.
And if they did, your clients have 90 days from the date of the notice to petition the Tax Court. The shutdown didn’t freeze or extend that clock.
If the 90 days ended during the shutdown, and you haven't petitioned the court, you're late. If the 90 days date is still in the future, remember the shutdown did extend that date.
2. Penalties Didn’t Pause Just Because the Government Did
Failure-to-file and failure-to-pay penalties continued to accrue the whole time.
The only exception? If a taxpayer had to make deposits or payments in person at a Taxpayer Assistance Center and couldn’t because that office was closed. Those clients may qualify for reasonable cause abatement.
But otherwise, the meter kept running.
This is where many professionals get stuck—clients assume “the government was shut down so my penalties shouldn’t count.”
Unfortunately, that's not true.
3. Revenue Officers Are Sorting Through Backlogs—Expect Delays and Surprises
Some ROs stayed active during the shutdown, working “limited cases” to protect government revenue.
Others were furloughed.
Now they’re all back, and they’re combing through:
Backlogged messages
Mail piles
Missed appointments
Interrupted payment plan negotiations
If your client missed a meeting during the shutdown, reach out to the RO to reschedule and ensure they know you're on top of things.
If your client was working toward an installment agreement, that conversation will restart.
There will be lag time. There will be confusion. There will be clients convinced the IRS “forgot about them.”
They didn’t.
4. Levies, and Passport Certifications Are Moving Again
A shutdown doesn’t stop IRS enforcement—it just slows it down.
Now that staffing has returned:
Levies and wage garnishments are being enforced again
Passport certifications for seriously delinquent taxpayers are resuming
Don't let your client be lulled into comfort. The IRS may be backed up, but I wouldn't wait around for a surprise.
That levy may have been on the proverbial tip of their tongue and now that the IRS is back in action, that levy is now going out.
5. Lien Discharges, Subordinations, and Withdrawals Are Back in Motion
During the shutdown, the IRS kept a skeleton crew handling only the most urgent lien-related matters—mainly where government revenue was at risk.
Now full operations have resumed, and Advisory Offices are processing:
Requests for discharge
Requests for subordination
Requests for lien withdrawal
This matters for:
Real estate closings
Refinancing
Business loans
Sales of property
Clearing title issues
If your client submitted a request during the shutdown, it should now be reviewed, but no one was reviewing it during the shutdown.
Assume the review clock is starting again now. Expect delays.
If they have an imminent closing? They can use Publication 4235 to identify the correct Advisory Office.
This is the moment where proactive professionals make the difference between a smooth transaction and a crisis.
TL;DR — What Professionals Need to Know
⏩ The IRS resumed full operations, and collection activity is accelerating quickly.
⏩ Statutory Notices of Deficiency still carry a strict 90-day response deadline.
⏩ Penalties continued to accrue during the shutdown.
⏩ Revenue Officers are re-engaging and reviewing missed appointments and payment plans.
⏩ Bank levies, wage garnishments and passport holds are back in motion.
⏩ Lien discharges, subordinations, and withdrawals are now being processed again.
➥ Contact Attorney Stephen A. Weisberg for a free Tax Debt Analysis.
Contact Me Here: https://www.weisberg.tax/contact-1
Email: sweisberg@wtaxattorney.com
Phone/Text: (248) 971-0885
Address: 300 Galleria Officentre, Suite 402, Southfield, MI 48034
